Delhi High Court Acquits Appellant in Section 302 IPC Case: Highlights Inconsistent Witness Testimonies and Insufficient Evidence, Reaffirms “Benefit of the Doubt Must Go to the Accused”

Court’s Decision

The Delhi High Court overturned the conviction and life sentence of the appellant, who had been found guilty under Sections 302 (murder) read with 34 (common intention) of the Indian Penal Code (IPC). The Court ruled that the prosecution failed to prove the appellant’s guilt beyond a reasonable doubt due to inconsistencies in the testimonies of key witnesses and lack of concrete evidence linking the appellant to the crime.

Key observation: “Benefit of such a doubt ought to be given to the appellant.”

The Court acquitted the appellant but upheld the trial court’s directive regarding compensation for the victim’s family.

2. Facts

1. Incident:
   • On February 27, 2017, the complainant’s son (deceased) was allegedly assaulted near Sawan Park by a group of men, including the appellant.
   • The complainant (father of the deceased) stated that he saw the appellant and others holding down his son while a co-accused stabbed him multiple times.
2. Medical Treatment:
   • The deceased was rushed to Sunder Lal Jain Hospital and later to Safdarjung Hospital, where he succumbed to his injuries.
3. Investigation and Charges:
   • An FIR was registered based on the complainant’s statement.
   • The police arrested the appellant and others and charged them under Sections 302/34 IPC.
4. Trial Court’s Judgment:
   • The trial court convicted the appellant and sentenced him to life imprisonment, relying on witness testimonies that claimed the appellant was part of the group involved in the assault.

3. Issues

The Court examined the following key issues:

1. Whether the appellant’s involvement in the crime was proven beyond a reasonable doubt.
2. Whether inconsistencies in the testimonies of key witnesses impacted the prosecution’s case.
3. Whether the evidence demonstrated a common intention (Section 34 IPC) to commit murder.

4. Petitioner’s Arguments

The appellant challenged the conviction on several grounds:

1. Contradictory Witness Statements:
   • Key prosecution witnesses (family members of the deceased) gave conflicting accounts of the incident. For instance:
     • Some claimed the appellant informed the family about the assault.
     • Others claimed the appellant was actively involved in holding down the deceased.
   • The appellant argued that such contradictions rendered the prosecution’s case unreliable.
2. Absence of Direct Evidence:
   • The deceased’s statement, recorded in the PCR form, did not mention the appellant’s name, even though the deceased was familiar with him.
   • This omission cast doubt on the appellant’s alleged involvement.
3. No Evidence of Common Intention:
   • The prosecution failed to show prior planning or a meeting of minds among the accused, necessary to establish a common intention under Section 34 IPC.
4. Lack of Motive:
   • The appellant argued that the prosecution failed to establish any motive or reason for his alleged participation in the assault.

5. Respondent’s Arguments

The State countered the appellant’s claims:

1. Identification of Appellant:
   • Witnesses (family members of the deceased) consistently identified the appellant as being present at the scene of the crime and actively involved in the assault.
2. Role in the Crime:
   • It was argued that the appellant’s role in holding down the deceased enabled the co-accused to stab him, thus establishing his liability under Section 34 IPC.
3. Credibility of Witnesses:
   • The State maintained that the testimonies of prosecution witnesses were credible and corroborated each other.

6. Analysis of the Law

The Court analyzed the requirements under Sections 302 and 34 IPC:

1. Section 302 IPC:
   • The prosecution must prove that the accused was directly involved in committing the murder.
2. Section 34 IPC:
   • Liability arises only when the prosecution can prove a common intention and active participation in furtherance of that intention.

The Court noted that the evidence failed to meet these requirements. There was no direct evidence of the appellant committing the murder or acting in concert with the co-accused.

7. Precedent Analysis

The Court relied on key precedents:

1. Ashish Batham v. State of M.P.:
   • Courts must presume innocence unless guilt is proven beyond a reasonable doubt. Suspicion, however strong, cannot substitute proof.
2. Balu Sudam Khalde v. State of Maharashtra:
   • The Court emphasized that inconsistencies in witness testimonies and contradictions in evidence weaken the prosecution’s case.

These principles guided the Court’s conclusion that the prosecution failed to establish the appellant’s guilt.

8. Court’s Reasoning

The High Court outlined several key reasons for acquitting the appellant:

1. Deceased’s Statement:
   • The deceased did not name the appellant in his dying statement recorded in the PCR form. Since the deceased knew the appellant, his failure to name him was significant.
2. Contradictory Witness Testimonies:
   • Key witnesses (family members of the deceased) gave conflicting accounts:
     • Some claimed the appellant held the deceased down during the assault.
     • Others stated he was not at the scene but instead informed the family about the fight.
   • These contradictions created serious doubts about the appellant’s role.
3. Doubt on Common Intention:
   • There was no evidence of premeditation or coordination between the appellant and co-accused.
   • The incident appeared to be spontaneous, with no prior meeting of minds.
4. Hostile Witness:
   • A key witness, who transported the deceased to the hospital, denied seeing the appellant at the crime scene. This further undermined the prosecution’s case.

9. Conclusion

The High Court concluded that:

1. The evidence against the appellant was insufficient to sustain his conviction.
2. Inconsistencies in witness testimonies and lack of corroborative evidence cast serious doubt on the prosecution’s case.
3. The appellant was entitled to the benefit of the doubt and was acquitted of all charges.

The Court directed his immediate release, provided he was not required in any other case.

10. Implications

The judgment highlights the following:

1. High Standard of Proof in Criminal Cases:
   • The prosecution must prove its case beyond a reasonable doubt, especially in serious charges like murder.
2. Importance of Witness Credibility:
   • Contradictions and inconsistencies in witness testimonies can weaken the case and lead to acquittals.
3. Protection of Accused’s Rights:
   • Courts must ensure that the accused’s rights are upheld, and convictions are based on solid evidence, not mere suspicion.

This case reinforces the principle that the benefit of the doubt must always go to the accused when evidence is inconclusive.

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